Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Income deemed to accrue or arise in India - Royalty Income - conducting research activities - Article 13(3)of India-UK DTAA shows that the transaction shall fall under the ambit of Royalty only when payments are received from a buyer to exploit the underlying copyrights of an article or payment is made for information concerning industrial, commercial or scientific experience.- AT
Income deemed to accrue or arise in India - Royalty Income - conducting research activities - Article 13(3)of India-UK DTAA shows that the transaction shall fall under the ambit of Royalty only when payments are received from a buyer to exploit the underlying copyrights of an article or payment is made for information concerning industrial, commercial or scientific experience.- AT
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